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`CASE NO. 4:20-cv-00555-O
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`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`
`
`
`
`
`
`MIDAS GREEN TECHNOLOGIES, LLC,
` PLAINTIFF,
`
`V.
`
`IMMERSION SYSTEMS LLC,
` DEFENDANT.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF TEXAS
`FORT WORTH DIVISION
`
`
`§
`
`§
`
`§
`§
`§
`§
`§
`§
`
`§
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`
`
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`AGAINST IMMERSION SYSTEMS LLC
`Artie Pennington
`State Bar No. 24090324
`aapennington@hpkdlaw.com
`Hunt Pennington Kumar & Dula, PLLC
`609 Castle Ridge Rd., Ste. 315
`Austin, TX 78746
`Phone: (512) 766-6082
`Fax: (512) 233-2699
`
`James Crewse
`State Bar No. 24045722
`jcrewse@crewselawfirm.com
`Crewse Law Firm, PLLC
`5546 Goodwin Ave.
`Dallas, TX 75206
`Phone: (214) 394-2856
`Fax: (253) 252-8776
`
`ATTORNEY FOR PLAINTIFF
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`Plaintiff Midas Green Technologies, LLC ("MGT" or "Plaintiff"), by and through its counsel,
`
`hereby brings this action for patent infringement against Immersion Systems, LLC ("Immersion"
`
`or "Defendant") alleging infringement of the following validly issued patents: U.S. Patent No.
`
`10,405,457, entitled "Appliance Immersion Cooling System" (" '457 Patent"), a true and correct
`
`copy of which is attached hereto as Exhibit A, and U.S. Patent No. 10,820,446, entitled
`
`“Appliance Immersion Cooling System” (“ ‘446 Patent”), a true and correct copy of which is
`
`attached hereto as Exhibit B (collectively, “Patents-in-Suit”).
`
`I. PARTIES
`
`1. MGT is a Texas limited liability company with its principal place of business at 8107
`
`Springdale Road, Austin, Texas 78724.
`
`2. On information and belief, Immersion is a Texas limited liability company with its
`
`principal place of business at 4412 Summercrest Ct., Fort Worth, Texas 76109, and may be
`
`served by and through its registered agent BMS CAT Inc. at 5718 Airport Freeway, Haltom City,
`
`Texas 78117.
`
`II.
`
`JURISDICTION AND VENUE
`
`3. This lawsuit is a civil action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. § 101 et seq.
`
`4. The Court has subject matter jurisdiction of this action pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`5. On information and belief, Immersion is subject to this Court's specific and general
`
`personal jurisdiction, pursuant to due process and the Texas Long-Arm Statute, due at least to its
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`business in this forum, including at least a portion of the infringement alleged herein.
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`Furthermore, Immersion is subject to this Court's specific and general personal jurisdiction
`
`because it has a place of business within this District, including at 7546 Pebble Dr., Fort Worth,
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`Texas 76118.
`
`6. Without limitation, on information and belief, within this District and state, Immersion
`
`has used the patented inventions thereby committing, and continuing to commit, acts of patent
`
`infringement alleged herein. In addition, on information and belief, Immersion has derived
`
`revenues from its infringing acts occurring within the Northern District of Texas and Texas.
`
`7. Further, on information and belief, Immersion is subject to the Court’s general
`
`jurisdiction, including from regularly doing or soliciting business, engaging in other persistent
`
`courses of conduct, and deriving substantial revenue from goods and services provided to
`
`persons or entities in the Northern District of Texas and Texas. Further, on information and
`
`belief, Immersion is subject to the Court’s personal jurisdiction at least due to its sale of products
`
`and/or services within the Northern District of Texas. Immersion has committed such purposeful
`
`acts and/or transactions in the Northern District of Texas and Texas such that it reasonably
`
`should know and expect that it could be haled into this Court as a consequence of such activity.
`
`III.
`
`VENUE
`
`8. Venue is proper in this district under 28 U.S.C. §§ 1391(b) and 1400(b). On information
`
`and belief, Defendant has a place of business at 7546 Pebble Dr., Fort Worth, Texas 76118. On
`
`information and belief, from and within this District Defendant has committed at least a portion
`
`of the infringements at issue in this case.
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`IV.
`
`FACTUAL BACKGROUND
`
`A.
`
`THE ASSERTED PATENTS
`
`1. The’457 Patent
`
`9. The '457 Patent, entitled "Appliance Immersion Cooling System", was duly and legally
`
`issued on September 3, 2019 by the U.S. Patent and Trademark Office, and names Christopher L.
`
`Boyd of Austin, TX (US), James P. Koen of Round Rock, TX (US), David Christopher Laguna,
`
`of Austin, TX (US), Thomas R. Turner of Georgetown, TX (US), Kenneth D. Swinden of Hutto,
`
`TX (US), Mario Conti Garcia of Austin, TX (US), and John Charles Tribou of Austin, TX (US)
`
`as the inventors. The application leading to the '457 Patent is U.S. Patent Application Number
`
`14/355,533 and was filed on April 30, 2014. A true and correct copy of the '457 Patent is
`
`attached hereto as Exhibit A and incorporated herein by reference.
`
`10. The '457 Patent claims, according to at least one embodiment, among other things, an
`
`appliance immersion cooling system that includes a tank adapted to immerse in a dielectric fluid
`
`a plurality of electrical appliances, each in a respective appliance slot distributed vertically along,
`
`and extending transverse to, a long wall of the tank. The tank includes a weir, integrated
`
`horizontally into the long wall of the tank adjacent all appliance slots, having an overflow lip
`
`adapted to facilitate substantially uniform recovery of the dielectric fluid flowing through each
`
`appliance slot, and a dielectric fluid recovery reservoir positioned vertically beneath the overflow
`
`lip of the weir and adapted to receive the dielectric fluid as it flows over the weir. The appliance
`
`immersion cooling system also includes a primary circulation facility adapted to circulate the
`
`dielectric fluid through the tank. The primary circulation facility includes a plenum, positioned
`
`adjacent the bottom of the tank, adapted to dispense the dielectric fluid substantially uniformly
`
`upwardly through each appliance slot. The appliance cooling system also includes a secondary
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`fluid circulation facility adapted to extract heat from the dielectric fluid circulating in the primary
`
`circulation facility, and to dissipate to the environment the heat so extracted, and a control
`
`facility adapted to coordinate the operation of the primary and secondary fluid circulation
`
`facilities as a function of the temperature of the dielectric fluid in the tank.
`
`11. The '457 Patent also claims, according to at least one embodiment, among other things, a
`
`tank module adapted for use in an appliance immersion cooling system. The tank module
`
`includes a tank adapted to immerse in a dielectric fluid a plurality of electrical appliances, each
`
`in a respective appliance slot distributed vertically along, and extending transverse to, a long wall
`
`of the tank. The tank includes a weir, integrated horizontally into the long wall of the tank
`
`adjacent all appliance slots, having an overflow lip adapted to facilitate substantially uniform
`
`recovery of the dielectric fluid flowing through each appliance slot, and a dielectric fluid
`
`recovery reservoir positioned vertically beneath the overflow lip of the weir and adapted to
`
`receive the dielectric fluid as it flows over the weir. The tank module also includes a primary
`
`circulation facility adapted to circulate the dielectric fluid through the tank, including a plenum,
`
`positioned adjacent the bottom of the tank, adapted to dispense the dielectric fluid substantially
`
`uniformly upwardly through each appliance slot, and a control facility adapted to control the
`
`operation of the primary fluid circulation facility as a function of the temperature of the dielectric
`
`fluid in the tank.
`
`12. The '457 Patent also claims, according to at least one embodiment, among other things, a
`
`tank module adapted for use in an appliance immersion cooling system. The tank module
`
`includes a tank adapted to immerse in a dielectric fluid a plurality of electrical appliances, each
`
`in a respective appliance slot distributed vertically along, and extending transverse to, a long wall
`
`of the tank. The tank includes a weir, integrated horizontally into the long wall of the tank
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`adjacent all appliance slots, adapted to facilitate substantially uniform recovery of the dielectric
`
`fluid flowing through each appliance slot. The tank module also includes a primary circulation
`
`facility adapted to circulate the dielectric fluid through the tank, including a plenum, positioned
`
`adjacent the bottom of the tank, adapted to dispense the dielectric fluid substantially uniformly
`
`upwardly through each appliance slot, and a control facility adapted to control the operation of
`
`the primary fluid circulation facility as a function of the temperature of the dielectric fluid in the
`
`tank.
`
`13. MGT is the assignee of all right, title, and interest in the '457 Patent, including all rights
`
`to enforce and prosecute actions for infringement and to collect damages for all relevant times
`
`against infringers of the '457 Patent. Accordingly, MGT possesses the exclusive right and has
`
`standing to prosecute the present action for infringement of the '457 Patent by Immersion.
`
`2. The ‘446 Patent
`
`14. The '446 Patent, entitled "Appliance Immersion Cooling System", was duly and legally
`
`issued on October 27, 2020 by the U.S. Patent and Trademark Office, and names Christopher L.
`
`Boyd of Austin, TX (US), James P. Koen of Round Rock, TX (US), David Christopher Laguna,
`
`of Austin, TX (US), Thomas R. Turner of Georgetown, TX (US), Kenneth D. Swinden of Hutto,
`
`TX (US), Mario Conti Garcia of Austin, TX (US), and John Charles Tribou of Austin, TX (US)
`
`as the inventors. The application leading to the '446 Patent is U.S. Patent Application Number
`
`16/243,732 and was filed on January 09, 2019, and is a Continuation Application of the ‘457
`
`Patent filed April 30, 2014. A true and correct copy of the '446 Patent is attached hereto as
`
`Exhibit B and incorporated herein by reference.
`
`15. The ‘446 Patent claims, according to at least one embodiment, among other things an
`
`appliance immersion cooling system that includes a tank adapted to immerse in a dielectric fluid
`
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`a plurality of electrical appliances, each in a respective appliance slot distributed vertically along,
`
`and extending transverse to, a long wall of the tank. The tank includes a weir, integrated
`
`horizontally into the long wall of the tank adjacent all appliance slots, adapted to facilitate
`
`substantially uniform recovery of the dielectric fluid flowing through each appliance slot. The
`
`appliance immersion cooling system also includes a primary circulation facility adapted to
`
`circulate the dielectric fluid through the tank. The primary circulation facility includes a plenum,
`
`positioned adjacent the bottom of the tank, adapted to dispense the dielectric fluid substantially
`
`uniformly upwardly through each appliance slot. The appliance cooling system also includes a
`
`secondary fluid circulation facility adapted to extract heat from the dielectric fluid circulating in
`
`the primary circulation facility, and to dissipate to the environment the heat so extracted, and a
`
`control facility adapted to coordinate the operation of the primary and secondary fluid circulation
`
`facilities as a function of the temperature of the dielectric fluid in the tank.
`
`16. The '446 Patent also claims, according to at least one embodiment, among other things, a
`
`tank module adapted for use in an appliance immersion cooling system. The tank module
`
`includes a tank adapted to immerse in a dielectric fluid a plurality of electrical appliances, each
`
`in a respective appliance slot distributed vertically along, and extending transverse to, a long wall
`
`of the tank. The tank includes a weir, integrated horizontally into the long wall of the tank
`
`adjacent all appliance slots, adapted to facilitate substantially uniform recovery of the dielectric
`
`fluid flowing through each appliance slot. The tank module also includes a primary circulation
`
`facility adapted to circulate the dielectric fluid through the tank, including a plenum, positioned
`
`adjacent the bottom of the tank, adapted to dispense the dielectric fluid substantially uniformly
`
`upwardly through each appliance slot; and a control facility adapted to control the operation of
`
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`the primary fluid circulation facility as a function of the temperature of the dielectric fluid in the
`
`tank.
`
`17. MGT is the assignee of all right, title, and interest in the '446 Patent, including all rights
`
`to enforce and prosecute actions for infringement and to collect damages for all relevant times
`
`against infringers of the '446 Patent. Accordingly, MGT possesses the exclusive right and has
`
`standing to prosecute the present action for infringement of the '446 Patent by Immersion.
`
`B.
`
`IMMERSION'S INFRINGING ACTIVITIES AND PRODUCTS
`
`18. On Friday, 07 February 2020, MGT had delivered to Immersion a demand letter and an
`
`accompanying claim chart detailing how the "457 Patent reads on the Accused Product ("Feb
`
`Demand Letter").
`
`19. On information and belief, Immersion has directly infringed claims of the '457 Patent in
`
`the Northern District of Texas, the State of Texas, and elsewhere in the United States, by at least
`
`making, using, selling, and offering for sale an apparatus for an appliance immersion cooling
`
`system that satisfies each and every limitation of at least claims 1, 6, and 11 of the '457 Patent,
`
`including, without limitation, at least Immersion’s Immersion System as represented at
`
`https://immersionsystems.io/media/ ("Accused Product").
`
`20. On information and belief, Immersion has directly infringed claims of the '446 Patent in
`
`the Northern District of Texas, the State of Texas, and elsewhere in the United States, by at least
`
`making, using, selling, and offering for sale an apparatus for an appliance immersion cooling
`
`system that satisfies each and every limitation of at least claims 1, and 6 of the '446 Patent,
`
`including, without limitation, at least the Accused Product.
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`V.
`
`COUNT 1
`
`(PATENT INFRINGEMENT OF U.S. U.S. PATENT NO. 10,405,457)
`
`21. MGT incorporates the allegations of the above paragraphs herein by reference, the same
`
`as if set forth herein.
`
`22. The '457 Patent was filed April 30, 2014, and legally issued by the United States Patent
`
`and Trademark Office ("USPTO") on September 3, 2019. The '457 Patent is presumed valid and
`
`enforceable pursuant to 35 U.S.C. § 282.
`
`23. Without a license or permission from MGT, Immersion has infringed and/or continue to
`
`infringe one or more claims of the '457 Patent – directly, contributorily, and/or by inducement –
`
`by importing, making, using, offering for sale, or selling products and devices that embody the
`
`patented invention, including without limitation, one or more of the patented '457 claims, in
`
`violation of 35 U.S.C. § 271.
`
`A.
`
`DIRECT INFRINGEMENT
`
`24. On information and belief, Immersion has directly infringed claims of the '457 Patent in
`
`the Northern District of Texas, the State of Texas, and elsewhere in the United States, by at least
`
`making, using, selling, and offering for sale an appliance immersion cooling system that satisfies
`
`each and every limitation of at least claims 1, 6, and 11 of the '457 Patent, including, without
`
`limitation, at least the Accused Product, in violation of 35 U.S.C. § 271(a). If any limitation of at
`
`least claims 1, 6, and 11 of the ‘457 Patent is not practiced in a literal sense by at least the
`
`Accused Product, then that limitation is present under the doctrine of equivalents.
`
`25. Attached hereto as Exhibit C is an exemplary claim chart detailing representative
`
`infringement of claim 1 of the '457 Patent by Immersion.
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`26. Attached hereto as Exhibit D is an exemplary claim chart detailing representative
`
`infringement of claim 6 of the '457 Patent by Immersion.
`
`27. Attached hereto as Exhibit E is an exemplary claim chart detailing representative
`
`infringement of claim 11 of the '457 Patent by Immersion.
`
`B.
`
`INDUCED INFRINGEMENT
`
`28. On information and belief, Immersion has been and is inducing infringement of MGT's
`
`'457 Patent by actively and knowingly inducing others to make, use, sell, offer for sale, or import
`
`at least the Accused Product that embody or use the invention claimed in the '457 Patent in
`
`violation of 35 U.S.C. § 271(b).
`
`29. Immersion induced infringement by publication of documents for using at least the
`
`Accused Product in an infringing manner, as well as advertising infringing uses to the '457
`
`Patent. Immersion's customers' subsequent usage of the Accused Products to cool electronic
`
`appliances via immersion placed every element of at least claim 1, 6, and 11 of the '457 Patent
`
`into service, constituting control and therefore infringement.
`
`30. Defendant's infringement has been, and continues to be knowing, intentional, and willful,
`
`at least beginning 07 February 2020 with the delivery of MGT's first notice letter and
`
`accompanying claim chart.
`
`31. Immersion's acts of infringement of the '457 Patent have caused and will continue to
`
`cause MGT damages for which MGT is entitled to compensation pursuant to 35 U.S.C. § 284.
`
`32. Immersion's acts of infringement of the ‘457 Patent have caused and will continue to
`
`cause MGT immediate and irreparable harm unless such infringing activities are enjoined by this
`
`Court pursuant to 35 U.S.C. § 283. MGT has no adequate remedy at law.
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`33. This case is exceptional and, therefore, MGT is entitled to an award of attorney fees
`
`pursuant to 35 U.S.C. § 285.
`
`VI.
`
`COUNT 2
`
`(PATENT INFRINGEMENT OF U.S. U.S. PATENT NO. 10,820,446)
`
`34. MGT incorporates the allegations of the above paragraphs herein by reference, the same
`
`as if set forth herein.
`
`35. The '446 Patent was filed January 09, 2019, and legally issued by the United States Patent
`
`and Trademark Office ("USPTO") on October 27, 2020. The '446 Patent is presumed valid and
`
`enforceable pursuant to 35 U.S.C. § 282.
`
`36. Without a license or permission from MGT, Immersion has infringed and/or continue to
`
`infringe one or more claims of the '446 Patent – directly, contributorily, and/or by inducement –
`
`by importing, making, using, offering for sale, or selling products and devices that embody the
`
`patented invention, including without limitation, one or more of the patented '446 Patent claims,
`
`in violation of 35 U.S.C. § 271.
`
`A.
`
`DIRECT INFRINGEMENT
`
`37. On information and belief, Immersion has directly infringed claims of the '446 Patent in
`
`the Northern District of Texas, the State of Texas, and elsewhere in the United States, by at least
`
`making, using, selling, and offering for sale an apparatus for an appliance immersion cooling
`
`system that satisfies each and every limitation of at least claims 1 and 6 of the '446 Patent,
`
`including, without limitation, at least the Accused Product, in violation of 35 U.S.C. § 271(a). If
`
`any limitation of at least claims 1 and 6 of the ‘446 Patent is not practiced in a literal sense by at
`
`least the Accused Product, then that limitation is present under the doctrine of equivalents.
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`38. Attached hereto as Exhibit F is an exemplary claim chart detailing representative
`
`infringement of claim 1 of the '446 Patent by Immersion.
`
`39. Attached hereto as Exhibit G is an exemplary claim chart detailing representative
`
`infringement of claim 6 of the '446 Patent by Immersion.
`
`B.
`
`INDUCED INFRINGEMENT
`
`40. On information and belief, Immersion has been and is inducing infringement of MGT's
`
`'446 Patent by actively and knowingly inducing others to make, use, sell, offer for sale, or import
`
`at least the Accused Product that embody or use the invention claimed in the '446 Patent in
`
`violation of 35 U.S.C. § 271(b).
`
`41. Immersion induced infringement by publication of documents for using at least the
`
`Accused Product in an infringing manner, as well as advertising infringing uses to the '446
`
`Patent. Immersion's customers' subsequent usage of the Accused Products to cool electronic
`
`appliances via immersion placed every element of at least claim 1, and 6 of the '446 Patent into
`
`service, constituting control and therefore infringement.
`
`42. Defendant's infringement has been, and continues to be knowing, intentional, and willful.
`
`43. Immersion's acts of infringement of the '446 Patent have caused and will continue to
`
`cause MGT damages for which MGT is entitled to compensation pursuant to 35 U.S.C. § 284.
`
`44. Immersion's acts of infringement of the ‘446 Patent have caused and will continue to
`
`cause MGT immediate and irreparable harm unless such infringing activities are enjoined by this
`
`Court pursuant to 35 U.S.C. § 283. MGT has no adequate remedy at law.
`
`45. This case is exceptional and, therefore, MGT is entitled to an award of attorney fees
`
`pursuant to 35 U.S.C. § 285.
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`VII.
`
`JURY DEMAND
`
`46. Pursuant to Rule 38 of the Federal Rules of Civil Procedure, MGT requests a trial by jury
`
`of any issues so triable by right.
`
`VIII.
`
`PRAYER
`
`WHEREFORE, MGT requests judgment against Immersion as follows:
`
`47. Adjudging that Immersion has directly infringed, and actively induced infringement of
`
`the '457 Patent, in violation of 35 U.S.C. § 271(a) and (b);
`
`48. Adjudging that Immersion has directly infringed, and actively induced infringement of
`
`the ‘446 Patent, in violation of 35 U.S.C. § 271(a) and (b);
`
`49. Granting an injunction preliminarily, and permanently enjoining Immersion, its
`
`employees, agents, officers, directors, attorneys, successors, affiliates, subsidiaries, and assigns,
`
`and all of those in active concert and participation with any of the foregoing persons or entities
`
`from infringing, contributing to the infringement of, or inducing infringement of the ‘457 Patent
`
`and of the ‘446 Patent;
`
`50. Ordering Immersion to account and pay damages adequate to compensate MGT for
`
`Immersion's infringement of, and inducement to infringe, the '457 Patent and the ‘446 Patent,
`
`including pre-judgment and post-judgment interest and costs, pursuant to 35 U.S.C. § 284;
`
`51. Ordering an accounting by Immersion for any infringing sales not presented at trial and
`
`an award by the court of additional damages for any such infringing sales to MGT;
`
`52. Ordering that the damages award be increased up to three times the actual amount
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`assessed, pursuant to 35 U.S.C. § 284;
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`
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`Case 4:20-cv-00555-O Document 34 Filed 11/24/20 Page 14 of 15 PageID 230Case 4:20-cv-00555-O Document 34 Filed 11/24/20 Page 14 of 15 PageID 230
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`53. Declaring this case exceptional and ordering Immersion to pay the costs of this action,
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`including all disbursements, and attorneys' fees as provided by 35 U.S.C. § 285, together with
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`prejudgment interest; and
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`54. Awarding such other and further relief as this Court deems just and proper.
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`DATED this 19th day of November, 2020.
`
`Respectfully submitted,
`
`/s/ Artie Pennington
`Artie Pennington
`State Bar No. 24090324
`aapennington@hpkdlaw.com
`Hunt Pennington Kumar & Dula, PLLC
`609 Castle Ridge Rd., Ste. 315
`Austin, TX 78746
`Phone: (512) 766-6082
`Fax: (512) 233-2699
`
`James Crewse
`State Bar No. 24045722
`jcrewse@crewselawfirm.com
`Crewse Law Firm, PLLC
`5546 Goodwin Ave.
`Dallas, TX 75206
`Phone: (214) 394-2856
`Fax: (253) 252-8776
`
`ATTORNEYS FOR PLAINTIFF
`
`
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`Case 4:20-cv-00555-O Document 34 Filed 11/24/20 Page 15 of 15 PageID 231Case 4:20-cv-00555-O Document 34 Filed 11/24/20 Page 15 of 15 PageID 231
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`CERTIFICATE OF SERVICE
`I certify that on the 19 day of November, 2020, I electronically filed the foregoing with the
`
`Clerk of Court using the CM/ECF system which will send notification of such filing to the
`
`following:
`
`Peter M. Spingola
`(Application for Admission Pro Hac Vice to be Filed)
`Illinois Bar No. 6243942
`e-Mail: pspingola@chapmanspingola.com
`Alexander Karl
`(Application for Admission Pro Hac Vice to be Filed)
`Illinois Bar No. 6329903
`e-Mail: akarl@chapmanspingola.com
`CHAPMAN SPINGOLA, LLC
`190 South LaSalle Street, Ste. 3850
`Chicago, IL 60603
`Telephone:
`(312) 630-9202
`Facsimile:
`(312) 630-9233
`- and-
`Kenneth C. Riney
`Texas Bar No. 24046721
`e-Mail: kriney@krcl.com
`Andrew D. Robertson
`Texas Bar No. 24090845
`e-Mail: drobertson@krcl.com
`KANE RUSSELL COLEMAN LOGAN PC
`901 Main Street, Ste. 5200
`Dallas, TX 75202
`Telephone:
`(214) 777-4200
`Facsimile:
`(214) 777-4299
`COUNSEL FOR DEFENDANT
`
`Respectfully submitted,
`
`By: /s/ Artie Pennington
`Artie Pennington
`
`
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`Case 4:20-cv-00555-O Document 34-1 Filed 11/24/20 Page 1 of 16 PageID 232Case 4:20-cv-00555-O Document 34-1 Filed 11/24/20 Page 1 of 16 PageID 232
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`EXHIBIT A
`{'457 Patent}
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`
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`Case 4:20-cv-00555-O Document 34-1 Filed 11/24/20 Page 2 of 16 PageID 233Case 4:20-cv-00555-O Document 34-1 Filed 11/24/20 Page 2 of 16 PageID 233
`US010405457B2
`
`( 12 ) United States Patent
`Boyd et al .
`
`( 10 ) Patent No . : US 10 , 405 , 457 B2
`( 45 ) Date of Patent :
`Sep . 3 , 2019
`
`( 54 ) APPLIANCE IMMERSION COOLING
`SYSTEM
`( 71 ) Applicants : Christopher L . Boyd , Austin , TX ( US ) ;
`James P . Koen , Round Rock , TX ( US ) ;
`David Christopher Laguna , Austin ,
`TX ( US ) ; Thomas R . Turner ,
`Georgetown , TX ( US ) ; Kenneth D .
`Swinden , Hutto , TX ( US ) ; Mario
`Conti Garcia , Austin , TX ( US ) ; John
`Charles Tribou , Austin , TX ( US )
`( 72 ) Inventors : Christopher L . Boyd , Austin , TX ( US ) ;
`James P . Koen , Round Rock , TX ( US ) ;
`David Christopher Laguna , Austin ,
`TX ( US ) ; Thomas R . Turner ,
`Georgetown , TX ( US ) ; Kenneth D .
`Swinden , Hutto , TX ( US ) ; Mario
`Conti Garcia , Austin , TX ( US ) ; John
`Charles Tribou , Austin , TX ( US )
`( 73 ) Assignee : Midas Green Technologies , LLC ,
`Austin , TX ( US )
`Subject to any disclaimer , the term of this
`patent is extended or adjusted under 35
`U . S . C . 154 ( b ) by 680 days .
`14 / 355 , 533
`Dec . 13 , 2013
`PCT / US2013 / 075126
`
`( * ) Notice :
`
`( 21 ) Appl . No . :
`( 22 ) PCT Filed :
`( 86 ) PCT No . :
`$ 371 ( c ) ( 1 ) ,
`Apr . 30 , 2014
`( 2 ) Date :
`( 87 ) PCT Pub . No . : WO2014 / 109869
`PCT Pub . Date : Jul . 17 , 2014
`Prior Publication Data
`US 2015 / 0181762 A1 Jun . 25 , 2015
`Related U . S . Application Data
`( 60 ) Provisional application No . 61 / 737 , 200 , filed on Dec .
`14 , 2012 , provisional application No . 61 / 832 , 211 ,
`filed on Jun . 7 , 2013 .
`
`( 65 )
`
`( 58 )
`
`( 56 )
`
`1 )
`
`2 )
`
`Int . CI .
`( 2006 . 01 )
`HOIL 23 / 44
`H05K 7 / 20
`( 2006 . 01 )
`U . S . CI .
`CPC . . . . . . . . . H05K 7 / 20236 ( 2013 . 01 ) ; H01L 23 / 44
`( 2013 . 01 ) ; H05K 7 / 20272 ( 2013 . 01 )
`Field of Classification Search
`CPC . . . . . . . . . . . . . . . . . . . . . . HO5K 7 / 20236 ; HO5K 7 / 20272 ;
`HO1L 23 / 42 ; HO1L 23 / 44
`( Continued )
`References Cited
`U . S . PATENT DOCUMENTS
`4 , 590 , 538 A *
`5 / 1986 Cray , Ir . . . . . . . . . . . HO5K 7 / 20236
`361 / 700
`5 , 167 , 511 A * 12 / 1992 Krajewski . . . . . . . . . . . . HO1R 4 / 01
`361 / 785
`( Continued )
`FOREIGN PATENT DOCUMENTS
`. . . G06F 1 / 20
`JP
`5956100 B1 *
`7 / 2016
`2042294 Ci
`RU
`8 / 1995
`1764094 AL
`SU
`9 / 1992
`Primary Examiner — Devon Russell
`( 74 ) Attorney , Agent , or Firm — Jeffrey Van Myers
`ABSTRACT
`( 57 )
`A appliance immersion tank system comprising : a generally
`rectangular tank adapted to immerse in a dielectric fluid a
`plurality of appliances , each in a respective appliance slot
`distributed vertically along , and extending transverse to , the
`long axis of the tank ; a primary circulation facility adapted
`to circulate the dielectric fluid through the tank ; a secondary
`fluid circulation facility adapted to extract heat from the
`dielectric fluid circulating in the primary circulation facility ,
`and to dissipate to the environment the heat so extracted ; and
`a control facility adapted to coordinate the operation of the
`primary and secondary fluid circulation facilities as a func
`tion of the temperature of the dielectric fluid in the tank . A
`plenum , positioned adjacent the bottom of the tank , is
`adapted to dispense the dielectric fluid substantially uni
`( Continued )
`
`34b
`
`706
`
`Wh
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`34a
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`y
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`36
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`Il
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`wwwwwww
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`US 10 , 405 , 457 B2
`Page 2
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`formly upwardly through each appliance slot . A weir , inte
`grated horizontally into a long wall of the tank , is adapted to
`facilitate substantially uniform recovery of the dielectric
`fluid flowing through each appliance slot . All active and
`most passive components of both the primary and secondary
`fluid circulation facilities , and the control fac